“unexplained cash credit”

Cash Credits & Unexplained ItemsSection 68Section 687,118 judgments

The decision most relied on for unexplained cash credit is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on unexplained cash credit

Sumati Dayal v. CIT

214 ITR 801 · 1995 · Supreme Court

1,967

citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Orissa Corporation Pvt. Ltd.

159 ITR 78 · 1986 · Supreme Court

897

citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT

37 ITR 288 · 1959 · Supreme Court

570

citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

CIT v. P. Mohanakala

291 ITR 278 · 2007 · Supreme Court

525

citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Judgments citing unexplained cash credit

Madan Mohan Mishra, Mumbai vs. ITO 8(2)(4), Mumbai

Appeal is allowed for statistical purposes

ITA 795/MUM/2023[2011-12]Status: DisposedITAT Mumbai19 Feb 2024AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri S.L. JainFor Respondent: Smt. Mahita Nair

Section 142Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 54

therefore no cognizance of the claim can be taken. Accordingly, the AO treated the agricultural income of Rs. 22,70,575 as unexplained cash credit and taxed the same as income from other sources in the hands of the assessee. 5. The learned CIT(A), vide impugned order, while dismissing

Varindavan Fabrics Private Limited, Panipat vs. Income Tax Officer, Ward-5, Panipat

In the result, the appeal of the assessee is allowed

ITA 3227/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Feb 2024AY 2017-18

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshassessment Year: 2017-18 Vrindavan Fabrics Private Ito Limited, Delhi Sanoli Bye Vs Ward – 5 Panipat Pass, Huda Sector-29 Panipat 132103 Pan No.Aaccv7480N (Appellant) (Respondent) Appellant By Sh. Amit Kaushik, Advocate Respondent By Sh. Vivek Vardhan, Sr. Dr Date Of Hearing: 07/02/2024 Date Of Pronouncement: 19/02/2024 Order Per Saktijit Dey,Vp: This Is An Appeal By The Assessee Against The Order Dated 07.11.2023 Passed By National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. The Dispute In The Present Appeal Is Confined To Addition Of An Amount Of Rs.46,03,682/- U/S. 68 Of The Income Tax Act, 1961. 3. Briefly Stated The Facts Are, The Assessee Is A Resident Corporate Entity. For The Assessment Year Under Dispute, The Assessee Filed Its Return Of Income On 07.10.2017 Declaring Total Income Of Rs. 5,10,270/-. In Course Of Assessment Proceedings The Assessing Officer (Ao) Called Upon The Assessee To Furnish The Details Of Sundry Creditors & Trade Payables With Their Address, Pan Numbers Etc. Alleging That The Assessee Furnished The Details On 19.12.2019 I.E. At The Fag End Of The Year, Which Made Impossible Any Enquiry To Be Carried Out Regarding The Genuineness Of The Trade Payables, The Ao Added Back Trade Payables / Closing Balances In Respect Of Seven Parties Aggregating To Rs.46,03,682/-, By Treating It As Unexplained Cash Credit U/S. 68 Of The Act. Though, The Assessee Contested The Aforesaid Addition Before Learned Commissioner Appeals, However, The Addition Was Sustained.

Section 68

payables, the AO added back trade payables / closing balances in respect of seven parties aggregating to Rs.46,03,682/-, by treating it as unexplained cash credit u/s. 68 of the Act. Though, the assessee contested the aforesaid addition before learned Commissioner Appeals, however, the addition was sustained. 3. Before

Sh. Vibhav Jain, Ludhiana vs. DCIT, CC-III, Ludhiana

In the result, the ground no

ITA 355/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh16 Feb 2024AY 2013-14

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR

Section 10(36)Section 10(38)Section 143(1)Section 143(2)Section 153A

amounting to Rs. 99,16,874/- was treated as bogus and added to the total income of the assessee treating the same as unexplained cash credit under Section 68 of the Act. 4. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 4.1 During

Seema Gupta, Meerut vs. ITO, Ward-2(5), Meerut

The appeal of the assessee is allowed

ITA 2823/DEL/2023[2009-10]Status: DisposedITAT Delhi16 Feb 2024AY 2009-10

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharma

For Appellant: Shri Rohit Aggarwal, CAFor Respondent: Shri Shyam Singh, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 68Section 69

books of accounts have been maintained by the appellant and, therefore, no unexplained cash credit could be said to have been found recorded therein for making addition u/s 68 of the Act. 4. That the confirmation of addition of Rs.11,48,016/- u/s 69 of Act, as unexplained investment

Seema Gupta, Meerut vs. ITO, Ward 2(5), Meerut

The appeal of the assessee is allowed

ITA 2822/DEL/2023[2009-10]Status: DisposedITAT Delhi16 Feb 2024AY 2009-10

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharma

For Appellant: Shri Rohit Aggarwal, CAFor Respondent: Shri Shyam Singh, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 68Section 69

Dreamtech Constructions Pvt. Ltd., New Delhi vs. DCIT Circle-7(1), New Delhi

In the result, Appeal filed by the assessee in ITA No

ITA 91/DEL/2021[2012-13]Status: DisposedITAT Delhi16 Feb 2024AY 2012-13

Bench: or at the time of hearing of the appeal.”

Section 143(3)Section 68

incorrect in so far as addition made /sustained u/s 68 of the Act amounting to Rs 307,21,000 on account alleged unexplained cash credit without appreciating that no meaningful/objective enquiry at any stage is made by Ld AO on details made available at asst stage and merely on basis

Dreamtech Constructions Pvt Ltd., Delhi vs. DCIT Circle-10(1), New Delhi

In the result, Appeal filed by the assessee in ITA No

ITA 90/DEL/2021[2011-12]Status: DisposedITAT Delhi16 Feb 2024AY 2011-12

Bench: or at the time of hearing of the appeal.”

Section 143(3)Section 68

ITO, Ward- No. 4(4), New Delhi vs. Bharat Power Tech Ltd., New Delhi

In the result, appeal of the Revenue and Cross Objection filed

ITA 5226/DEL/2019[2011-12]Status: DisposedITAT Delhi16 Feb 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.5157/Del/2019 िनधा"रणवष"/Assessment Year: 2011-12 बनाम M/S Bharat Power Tech Ltd., The Income Tax Officer, E-21, Lower G/F, Kalkaji, Vs. Ward-2(4), Room No.381, New Delhi. New Delhi. Pan No.Aaacb1314P अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.5226/Del/2019 िनधा"रणवष"/Assessment Year: 2011-12 बनाम The Income Tax Officer, M/S Bharat Power Tech Ward-4(4), New Delhi. Vs. Ltd., E-21, Lower G/F, Kalkaji, New Delhi. Pan No.Aaacb1314P अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection No. 65/Del/2022 (In I.T.A No.5226/Del/2019) िनधा"रणवष"/Assessment Year: 2011-12 बनाम M/S Bharat Power Tech Ltd., The Income Tax Officer, E-21, Lower G/F, Kalkaji, Vs. Ward-4(4), New Delhi. New Delhi. Pan No.Aaacb1314P अपीलाथ" Appellant ""यथ"/Respondent

Section 68

addition with the following observations: “6.4 Ground no.4: - This ground is directed against addition of Rs.4,24,77,876/- u/s 68 as unexplained cash credit as all credit entries appearing in the bank statement have been considered as cash credit. After reducing the cash credit already disclosed, the said addition ... against FDR etc. 6.7 During remand proceedings, no comment is received on the bank statement already furnished during assessment proceeding and addition of unexplained cash credit u/s 68 in respect of share capital etc. is already made separately, this further I.T.A.Nos.5157, 5226/Del/2019 & CO No. 65/Del/2022 addition of all credit

Bharat Power Tech Ltd., New Delhi vs. ITO, Ward- No. 2(4), New Delhi

In the result, appeal of the Revenue and Cross Objection filed

ITA 5157/DEL/2019[2011-12]Status: DisposedITAT Delhi16 Feb 2024AY 2011-12

Section 68

Subhlaxmi Chem Pvt. Ltd, Kolkata vs. ITO, Ward-12(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 992/KOL/2023[2011-12]Status: DisposedITAT Kolkata15 Feb 2024AY 2011-12

Bench: Shri Rajesh Kumari.T.A. No. 992/Kol/2023 Assessment Year: 2011-2012 Subhlaxmi Chem Private Limited,...........Appellant R. No. C452, 71, B.R.B,B. Road, Bagri Market, Kolkata-700001 [Pan: Aahcs1598R] -Vs.- Income Tax Officer,.................................Respondent Ward-12(4), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri B.C. Jain, Fca, Appeared On Behalf Of The Assessee Shri Vijay Kumar, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : December 20, 2023 Date Of Pronouncing The Order : February 15, 2024 O R D E R

Section 143(1)Section 143(3)Section 147Section 148Section 68

details as requisitioned by the ld. Assessing Officer. Finally the ld. Assessing Officer treated the money receipt of Rs.45,00,000/- as unexplained cash credit in the books of account of the assessee under section 68 and added it to the total income of the assessee. In the appellate proceeding

Mr. Mohan, Chennai vs. ITO, Chennai

In the result, the appeal of the assessee is allowed for statistical purposes only

ITA 947/CHNY/2022[2016-2017]Status: DisposedITAT Chennai15 Feb 2024AY 2016-2017

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.947/Chny/2022 िनधा(रण वष( /Assessment Year: 2016-17 Shri Mohan, The Income Tax Officer, No.58, Barakha Road, Vs. Non Corporate Ward-10(3), Kilpauk, Chennai – 600 010. Chennai. [Pan: Aaipm-5498-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N Arjun Raj, C.A ""यथ" क" ओर से /Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 15.02.2024 घोषणा क" तारीख /Date Of Pronouncement : 15.02.2024

For Appellant: Shri N Arjun Raj, C.A ""For Respondent: Shri P. Sajit Kumar, JCIT

added this amount to the total income of the :- 2 -: assessee vide assessment order dated 20-12-2018 treating it as unexplained cash credit. Being aggrieved, the assessee filed appeal before the learned CIT(A) unsuccessfully. The ld. CIT(A) vide order dated 16-09-2022 dismissed the appeal

Shri Praveen Gupta, Gurgaon vs. ACIT, Meerut

In the result, the appeal of the assessee is dismissed

ITA 3189/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Feb 2024AY 2012-13

Bench: Shri Amit Shukla & Shri M. Balaganeshshri Praveen Gupta, Vs. Acit, D-101, First Floor, Tower Circle-2, No. D, Caitriona Meerut Residential Apartment Complex, Ambience Island, Gurgoan-22001 (Appellant) (Respondent) Pan: Acjpg4777H Assessee By : None Revenue By: Shri Vivek Vardha, Sr. Dr Date Of Hearing 12/02/2024 Date Of Pronouncement 15/02/2024

For Appellant: NoneFor Respondent: Shri Vivek Vardha, Sr. DR

Section 143(3)Section 37Section 68

part of assessee and hereby same is added in income of the assessee u/s 68 of the IT Act, 1961 as unexplained cash credit." 5.3.2 The AR submitted that this addition was made on account of unsecured loans received during the year mostly from relatives of the assessee. As already

Anil Kumar Tanwar, Bhiwadi vs. ITO Bhiwadi, Bhiwadi

In the result, the appeal of the assessee is allowed for statistical

ITA 36/JPR/2024[2009-10]Status: DisposedITAT Jaipur14 Feb 2024AY 2009-10

Bench: Nfac/ Commissioner Of Income Tax (Appeals), But The Nfac Has Failed To Consider It & Passed The Order On Dated 20.11.2023 & Dismiss The Appeal Which Deserved To Be Accepted.

For Appellant: Sh. P C Parwal (CA)For Respondent: Smt. Monisha Choudhary (Addl. CIT)

Section 142(1)Section 144Section 148

addition of an equal amount was made by the AO in the hands of Shri Pratap Singh Tanwar by treating the same as unexplained cash credit. Shri Pratap Singh Tanwar preferred an appeal which was admitted and addition of Rs. 33,48,500/- was deleted with an observation that ... addition of Rs.33,48,500/- was made by the AO in the case of Shri Pratap Singh Tanwar on account of unexplained cash credit. Shri Tanwar preferred an appeal before the CIT(A) against the addition and the CIT(A) deleted the addition observing that the AO might pass

Bharat Bhushan Bansal, New Delhi vs. ITO Ward - 43(1), New Delhi

In the result, appeal of the assessee is partly allowed as

ITA 7459/DEL/2019[2013-14]Status: DisposedITAT Delhi14 Feb 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.7459/Del/2019 िनधा"रणवष"/Assessment Year: 2013-14

Section 143(2)Section 144Section 56Section 68

making addition of Rs.5,74,276/-. 4. The Ld. CIT(A) was not justified in making addition of Rs.20,34,004/- as unexplained cash credit since the assessee was prevented by sufficient cause in furnishing relevant documents confirming the credit worthiness and genuineness of transaction. 5. The Ld.CIT ... justified in making addition of Rs.50,000/- as unexplained cash credits since the assessee was prevented by sufficient cause in furnishing relevant documents confirming the financial capacity and genuineness of donor. 6. The Ld.CIT(A) was not justified in making addition of Rs.17,33,100/- as unexplained cash credit since

Nanjappa Gounder Palanisamy, Coimbatore vs. ITO, Non Corporate Ward-3(2), Coimbatore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1227/CHNY/2023[2017-18]Status: DisposedITAT Chennai13 Feb 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.1227/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18

For Appellant: Shri Shrenik Chordia, CAFor Respondent: Shri AR V Sreenivasan, Addl. CIT

Section 131Section 143(1)Section 143(3)Section 68

Officer granted relief of ₹.52.89,400/- and the balance amount of ₹.23,20,600/- [₹.76,10,000 - ₹.52,89,400/-] was treated as unexplained cash credit under section 68 of the Act and brought to tax. On appeal, the ld. CIT(A) dismissed the appeal for want of prosecution

Prince Rodde, Mumbai vs. ITO Ward 34 (4), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 3397/MUM/2023[2012-13]Status: DisposedITAT Mumbai13 Feb 2024AY 2012-13

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Prince Rodde Ito, Ward 16(1)(3), Mumbai 702, Palms 2 Royal Palms, Earlier Known As Ito Ward 34(4), Mayur Nagar, Aarey Colony, Vs. New Delhi Goregaon East, Mumbai-400 065

For Appellant: Shri Bharat KumarFor Respondent: Shri Surendra Kumar Meena

Section 147Section 148Section 250Section 68Section 69

Rs.5,33,771/- which is the salary received by the assessee other than as a government employee and treated the same as ‘unexplained cash credit’ u/s. 68 of 4 Prince Rodde vs. ITO the Act. The assessee is said to have filed additional evidences before the first appellate authority under

Raina Garg, Bhopal vs. CIT(A), Delhi

Appeal is partly allowed

ITA 334/IND/2023[2015-16]Status: HeardITAT Indore12 Feb 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2015-16 Raina Garg, Ito-4(1), Prop. M/S. Garg Trading Bhopal Company, बनाम/ Purana Kabadkhana, Vs. Jumerati, Bhopal (Appellant/Assessee) (Respondent/Revenue) Pan: Aawpg4732F Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 06.02.2024 Date Of Pronouncement 12.02.2024

Section 143(2)Section 143(3)Section 40A(2)

explain genuineness of transaction and creditworthiness of the lender and therefore, the addition of Rs. 4,00,000/- made by AO being unexplained cash credit is hereby confirmed. Therefore, this ground of appeal is also dismissed.” Ld. DR submitted that the assessee has failed to prove the creditworthiness ... Page 10 of 18 Raina Garg, Bhopal ITA No. 334/Ind/2023 – AY 2015-16 “GROUND NO. 2 (Addition of Rs. 4,00,000/- as unexplained cash credit) Page 11 of 18 Raina Garg, Bhopal ITA No. 334/Ind/2023 – AY 2015-16 11. From submissions of assessee, following facts emerge: (i) The assessee

Lata Kaman, Gulbarga vs. Income Tax Officer, Ward-1 & Tps, Kalaburgi

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 1103/BANG/2023[2018-19]Status: DisposedITAT Bangalore12 Feb 2024AY 2018-19

Bench: Chandra Poojari & Shri Narendra Kumar Chodhryassessment Year : 2018-19 Smt. Lata Kaman, Vs. Ito, E2803, Bapunagar Harijanwada, Ward – 1 & Tps, Gulbarga – 585 102, Kalaburgi, Karnataka. Karnataka. Pan : Ahnpl 2584 L Appellant Respondent Assessee By : Shri. Sreehari Kutsa, Advocate Revenue By : Shri. Ganesh R Ghale, Advocate – Standing Counsel For Revnue. Date Of Hearing : 12.02.2024 Date Of Pronouncement : 12.02.2024

For Appellant: Shri. Sreehari Kutsa, AdvocateFor Respondent: Shri. Ganesh R Ghale, Advocate – Standing Counsel for Revnue

Section 115BSection 142(1)Section 144Section 148Section 154Section 250Section 68Section 69A

Grievance of the assessee in this appeal is with regard to addition of Rs.20 lakhs made by AO as unexplained cash credit. The AO got information regarding cash deposit in savings bank account during the FY 2017-18 relevant to AY 2018- 19. The description of information is regarding time

ACIT, CC- 15, New Delhi vs. Meghalaya Infratech Ltd., New Delhi

Appeal of the Revenue is dismissed in terms as indicated

ITA 3910/DEL/2017[2012-13]Status: HeardITAT Delhi12 Feb 2024AY 2012-13

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatassessment Year: 2012-13

Section 14Section 15Section 31Section 33Section 68Section 7

case the CIT(A) has erred in deleting the addition of Rs.5,78,00,000/-made by AO on account of unexplained cash credit u/s 68 of the I.T. Act, 1961. 2. The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during

Subodh Debnath, Kolkata vs. ITO, Ward-2(4), Raiganj

In the result, the appeal of the assessee stands allowed

ITA 1213/KOL/2023[2017-18]Status: DisposedITAT Kolkata09 Feb 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.1213/Kol/2023 Assessment Year : 2017-18 Subodh Debnath………………………………………….…………....Appellant C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Cldpd3024M] Vs. Ito, Ward-2(4), Kolkata…..…..........................................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Subhro Das, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 01, 2024 Date Of Pronouncing The Order : February 09, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 13.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. For That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Was Not Justified In Confirming The Addition Made By The A.O To The Tune Of Rs.17,00,000/- Being Cash Deposits During The Demonetization Period, By Wrongly Treating The Same As Unexplained Cash Credits U/S 69A Of The Act.

Section 250Section 69A

tune of Rs.17,00,000/- being cash deposits during the demonetization period, by wrongly treating the same as unexplained cash credits u/s 69A of the Act. I.T.A. No.1213/Kol/2023 Assessment Year : 2017-18 Subodh Debnath 2. Without prejudice to the above, the Ld. CIT(A) ought to have directed